Iowa Rule of Criminal Procedure 2.24(5) with the assistance of attorney Angela Fritz Reyes. On September 30, 2010, the district court issued an opinion declaring Graham retroactive. The court re-sentenced Means in absentia to life imprisonment and severed the non-parole portion of Iowa law, thereby granting Means the opportunity for parole. In at least two cases, state high courts have ruled that life without parole is still appropriate for homicides, no matter what age the defendant. On December 21, 2010, the Supreme Court of Missouri delivered its opinion in the case of State v. Anthony Andrews, affirming a sentence of life imprisonment without parole in a case in which the defendant, Andrews, was a juvenile convicted of first-degree murder. The Wisconsin Supreme Court on May 20, 2011, ruled similarly in State v. Omer Ninham, in a case in which Ninham was convicted as an adult of intentional homicide for a crime committed at the age of 14. Further developments In February 2012, Terrance Jamar Graham was re-sentenced by the original trial judge to a 25-year sentence and set to be released on August 16, 2025. In March 2012, the Court heard arguments in the case of Miller v. Alabama, concerning the constitutionality of mandatory life without parole sentences for juvenile offenders in cases including murder. The Court issued its ruling on June 25, 2012, striking down the mandatory sentences as cruel and unusual punishments in violation of the Eighth Amendment to the United States Constitution. Graham is currently incarcerated in the Charlotte Correctional Institution. References Further reading . . . External links United States Supreme Court cases United States Supreme Court cases of the Roberts Court 2010 in United States case law Life imprisonment Cruel and Unusual Punishment Clause case law United States children's rights case law